Norfolk PEEL 2018
How legitimately does the force treat the public and its workforce?
Norfolk Constabulary is good at treating the public fairly.
The workforce has an ethical culture at all levels. It has a culture of learning not blame. But the force’s counter-corruption unit is limited in its ability to pursue corruption proactively. A new IT monitoring system intended to protect the force’s data may put further pressure on this unit.
Norfolk Constabulary is good at treating the workforce fairly.
To what extent does the force treat all of the people it serves with fairness and respect?
This question was not subject to detailed inspection in 2018/19, and our judgment from the 2017 legitimacy inspection has been carried over. However, we reviewed a representative sample of 158 stop and search records to assess the reasonableness of the recorded grounds. We found that 88 percent had reasonable grounds recorded. Our assessment is based on the grounds recorded on the record by the searching officer and not the grounds that existed at the time of the search.
In our 2017 legitimacy report, we recommended that all forces should:
- monitor and analyse comprehensive stop and search data to understand reasons for disparities;
- take action on those; and
- publish the analysis and the action by July 2018.
We found that the force has complied with some of this recommendation. But it doesn’t identify the extent to which find rates differ between people from different ethnicities and between different types of searches (including separate identification of find rates for drug possession and supply-type offences). It also isn’t clear that the force monitors enough data to identify the prevalence of possession-only drug searches or the extent to which these align with local or force-level priorities.
We reviewed the force’s website and were unable to find the force’s analysis to understand reasons for disparities or an explanation of subsequent action taken.
We will continue to monitor progress in this area.
How well does the force ensure that its workforce behaves ethically and lawfully?
Areas for improvement
- The force should ensure its counter corruption unit has the capability and capacity to be effective in its proactive approach to counter corruption – and has full information technology (IT) monitoring to effectively protect the information contained within its systems.
We set out our detailed findings below. These are the basis for our judgment of the force’s performance in this area.
Maintaining an ethical culture
Norfolk Constabulary continues to develop and maintain an ethical culture. Its policies and procedures take account of the Code of Ethics. We found that the workforce
has a clear understanding of the code, and of standards of professional behaviour. Senior managers are leading this understanding. The workforce has a range of ways to submit and consider ethical issues, from one-to-one conversations with supervisors to local ‘sounding board’ meetings that feed in to a force-wide board – the ethics committee and the joint integrity board with Suffolk Constabulary. When mistakes are made, senior leaders have worked hard to develop a culture of learning, rather than blame. During our fieldwork, officers and staff offered us several good examples of when they had felt able to discuss such mistakes and seize the opportunity to learn lessons from them.
The force is following the new vetting code of practice and authorised professional practice. It manages all new vetting requests, whether for starters or internal postings, in an effective and timely fashion. The force meets its obligations to provide details to the College of Policing for the barred and advisory lists. These prevent people who have left the service under investigation, or been dismissed, from re-joining or working in law enforcement.
The head of the professional standards department (PSD) reviews disparities in vetting decisions, including refusals for black, Asian and minority ethnic applicants. These refusals are discussed at the PSD fortnightly tactical tasking meeting. The force has a small number of refusals, so the head of the PSD can review them directly.
The force recognises it should work to improve the quality of the data and information it holds about applicants’ protected characteristics. The PSD and human resources are working to improve matters.
The force will not meet our national recommendation for all forces to ensure that officers and staff have the minimum level of vetting required in their role by December 2018. However, its vetting backlog of 9 percent is lower than the average of all forces in England and Wales of 13 percent. The vetting unit for Norfolk Constabulary is run jointly with Suffolk Constabulary, but collaboration between the two separate units has caused some problems in terms of data quality and recording. This has resulted in the unit having a backlog of vetting records that are out of date and need to be reviewed and deleted. This might be where a person has resigned or had previously moved from a staff to a police officer role, for example. The force now has a clear understanding of the numbers of outstanding records and is working through them. This has been difficult, because of the level of resources available, but the vetting unit has gained some extra staff. At the time of our inspection fieldwork, we were aware of a bid to further increase staffing. This was being advanced through the force’s outcome-based budgeting process.
Various ways exist for the force to reduce risk in the outstanding vetting records. They include prioritising those in higher-risk posts, reviewing compliance with PSD policies, and gathering intelligence from the integrity check information that is now part of the performance and development review (PDR) process. The force also monitors this as part of its organisational risk register procedure.The force clarifies and reinforces standards of professional behaviour regularly through items on its intranet and through poster campaigns. The PSD has a communications plan with a specific focus each month, designed to continually improve the workforce’s understanding of professional standards. Officers and staff are aware of the PSD’s quarterly newsletter, called Lessons Learned. This highlights issues of misconduct and breaches of the standards of professional behaviour. It also supplies examples of how the workforce can learn from them. The force publicises the outcomes of serious complaints and gross misconduct investigations through the intranet. We found that most officers and staff considered this information useful. We found also that all of them had a clear understanding of the consequences of not following the Code of Ethics or standards of professional behaviour.
Our 2017 legitimacy inspection contained two areas for improvement. First, in line with IPCC guidance, the force was to improve the quality and timeliness of its updates to complainants, including matters of misconduct. During this inspection, we spoke with a regional officer from the Independent Office for Police Conduct (IOPC). We found that the force is now complying with IOPC guidance on the timeliness of managing complaints and mandatory referral criteria. Second, the force needed to improve its workforce’s understanding, so that it can identify, and respond appropriately and at the earliest opportunity to, reports of discrimination. We found that supervisors now get clear advice on this matter from the force’s intranet. The PSD reviews, records and refers all allegations to the IOPC, where required; a copy of the IOPC guidance is also given to investigators. The PSD oversees investigations and offers advice when needed. We are satisfied that the force has made suitable progress in addressing these two areas for improvement.
Norfolk Constabulary has an effective joint counter-corruption strategic threat assessment and control strategy in place with Suffolk Constabulary. This has been refreshed recently. The threat assessment identifies the main vulnerabilities, trends and emerging threats. It does not include drug use or supply as a category for analysis, but we found that the control strategy identifies this as an intelligence gap for the force.
The force reviews notifiable associations effectively to identify individuals who may be susceptible to corruption. We found that reviews are carried out more often on individuals perceived to be of greater risk to the force. We consider this good practice. The anti-corruption unit (ACU) has recently introduced a process to review refused business interests after three months. The number of cases is small, and this process is still being put in place. Support is available to those people the ACU has identified as being at risk of corruption. This includes the provision of early interventions, such as debt counselling. These interventions are not monitored or evaluated, however. The force should consider doing this, to be sure that these services are effective in preventing potential corruption.
The limited capacity and capability of the force’s ACU means its ability to do proactive work is restricted. But we found that if a concern is raised that requires a reactive approach, the force can quickly obtain support locally to deal with it. The ACU effectively manages the information and intelligence it receives. But we found
that the way it records this intelligence does not always align with nationally recognised categories. The result is that it may be difficult to identify and analyse trends in corruption. The force should review the initial classification process within the ACU.
We found that the force now has software to carry out real-time monitoring of its ICT systems, including those on mobile devices, besides its standard auditing capabilities. Testing of this monitoring software was being completed at the time of our fieldwork. This is being rolled out for all office-based hardware. Mobile devices are to follow
in early 2019. The force is aware that live-time ICT monitoring could potentially increase the demand on the ACU, which has little scope to take on extra proactive work. The ACU’s capacity was reviewed at the end of 2018 as part of the force’s outcome-based budgeting process; agreement was reached to recruit into a vacant post. The head of the PSD and the deputy chief constable continue to closely and regularly monitor the effect on resources of ICT monitoring software.
Confidential processes are in place to effectively report wrongdoing. Officers and staff have a good understanding of how to do this and are generally confident that they can do so anonymously. We found the workforce felt they could approach the PSD if they had serious concerns and would be content to contact members of the department directly to discuss concerns and obtain advice.
The force views abuse of position for a sexual purpose as serious corruption. It is the main priority in its counter-corruption strategic threat assessment. It refers all cases appropriately to the IOPC. The workforce has a good understanding of abuse of position for a sexual purpose. We found the force had recently run a campaign to refresh the workforce’s awareness of developing inappropriate relationships with victims of crime.
We found that the force has a particularly innovative scheme to support victims of abuse of position for a sexual purpose. The force has excellent links with organisations that support vulnerable victims. One of the most recent referrals to the IOPC was initiated by information received from a sexual abuse support worker. A dedicated member of staff from Victim Support works with such victims throughout an investigation, at any hearing or court appearance, and beyond. This is available for victims in both criminal and misconduct cases. The victims are supported practically and emotionally. They are also helped to prepare for the court process. This aids them in providing the best evidence possible, and such cases are more likely to reach a positive conclusion. We consider this to be a positive approach in supporting vulnerable victims.
The ACU has also given supervisors individual training on identifying the early signs of abuse of position for a sexual purpose, and on what to do if they recognise such signs. The force has put this plan into practice in response to one of our 2016 national recommendations about the abuse of position for a sexual purpose. The only outstanding action from the recommendations is to start to implement a plan to ensure effective ICT monitoring tools. As we reported earlier in this section, resources to use these are in place. The force was rolling out monitoring software during our fieldwork and is reviewing its effect on resourcing within the ACU. We expect that this final action to meet the 2016 national recommendation will be completed in early 2019.Summary for question 2
To what extent does the force treat its workforce with fairness and respect?
This question was not subject to detailed inspection in 2018/19, and our judgment from the 2017 legitimacy inspection has been carried over. However, Norfolk Constabulary had two areas for improvement in the 2017 legitimacy inspection.
Areas for improvement
- The force needs to ensure that selection and promotion processes are open and fair, and are perceived to be so by the workforce.
- The force needs to ensure that the staff performance assessment framework is applied consistently and fairly across the entire organisation and that staff consider it valuable in supporting their development.
The force introduced a new PDR process for the 2018/19 performance year. During fieldwork, we found that this was still being put in place. But we found that the workforce understands that the PDR process is fundamental to identifying, documenting and supporting their development. We found also that it was being used to discuss promotion and development opportunities with line managers. Selection and promotion processes, as well as succession and workforce planning, are all clearly linked to the PDR process. We are satisfied that the force has suitably addressed these areas for improvement.